Free Motion for Extension of Time to File - District Court of California - California

Case 3:07-cv-02407-JAH-AJB

Document 19

Filed 04/11/2008

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1 JOHN M. BENASSI (SBN 74137) 2 MATTHEW C. LAPPLE (SBN 193546) 3 OWAIS SIDDIQUI (SBN 230004) 4 5 6 7 8 9 10
DAVID E. KLEINFELD (SBN 110734)

SAMUEL R. HELLFELD (SBN 234421) HELLER EHRMAN LLP 4350 La Jolla Village Drive, 7th Floor San Diego, CA 92122-1246 Telephone: 858.450.8400 Facsimile: 858.450.8499 [email protected] [email protected] [email protected] [email protected] Attorneys for Plaintiff PULSE~LINK, INC. TERRENCE P. MCMAHON (SBN 71910) JAMES W. SOONG (SBN 196092) 3150 Porter Drive

11 TIMUR S. ENGIN (SBN 229944)

12 MCDERMOTT WILL & EMERY LLP 13 Palo Alto CA 94304 14 Facsimile: 650.813.5100
Telephone: 650.813.5000

15 Attorneys for Defendant TZERO TECHNOLOGIES, INC. 16 17
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA CASE NO. 07 CV 2407 JAH (AJB) JOINT MOTION EXTENSION OF TIME FOR LODGING OF RULE 26(F) REPORT AND TELEPHONIC CASE MANAGEMENT CONFERENCE

18 PULSE~LINK INCORPORATED, 19 20 v. 21 TZERO TECHNOLOGIES INCORPORATED, 22 23 24 25 26 27
Heller Ehrman LLP

Plaintiff,

Defendant.

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JOINT MOTION EXTENSION OF TIME FOR LODGING OF RULE 26(F) REPORT AND TELEPHONIC CASE MANAGEMENT CONFERENCE 07 CV 2407 JAH (AJB)

Case 3:07-cv-02407-JAH-AJB

Document 19

Filed 04/11/2008

Page 2 of 2

1

Plaintiff Pulse~Link, Incorporated ("Pulse~Link") and Defendant Tzero Technologies, Inc.

2 ("Tzero") hereby jointly move the Court for a one week extension of time to lodge their Rule 26(f) 3 Joint Report, currently due on April 16, 2008, and for the Court to reschedule, by one week (or at a 4 time convenient for the Court), the telephonic Case Management Conference that is currently set 5 for April 23, 2008. 6
The Parties are currently in settlement negotiations to resolve both the above-captioned

7 action, as well as another pending action, namely 07 CV 2156 L (AJB), which was consolidated 8 with 07 CV 1125 L (AJB). The parties believe that settlement of the 07 CV 2156 L (AJB) and 07 9 CV 2407 JAH (AJB) actions are likely and are preparing documents to effectuate that settlement. 10 This settlement would not affect the remaining allegations pending in the 07 CV 1125 L (AJB) 11 action, but would narrow the dispute between the parties. Accordingly, to conserve the resources of 12 both the Court and the parties, the short extension of time requested above is appropriate. 13 14 DATED: April 11, 2008 15 16 17 18 DATED: April 11, 2008 19 20 21 22 23 24 25 26 27
Heller Ehrman LLP

Respectfully submitted, McDERMOTT, WILL & EMERY LLP

By:/s/ Timur S. Engin Attorneys for Defendant TZERO TECHNOLOGIES INC. HELLER EHRMAN LLP

By:/s/ Matthew C. Lapple Attorneys For Plaintiff PULSE~LINK INCORPORATED

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JOINT MOTION EXTENSION OF TIME FOR LODGING OF RULE 26(F) REPORT AND TELEPHONIC CASE MANAGEMENT CONFERENCE 07 CV 2407 JAH (AJB)